A powerful new tool for victims of fraud?  The UK SFO returns £400,000 to fraud victims 24 years after the crime

A significant development in civil recovery, victim compensation and limitation principles
8 January 2026

Executive Summary

The Serious Fraud Office (SFO) has announced the return of more than £400,000 to victims of a global email fraud, almost 24 years after the offences were committed. The recovery was achieved without a criminal conviction, through a novel use of civil recovery powers under the Proceeds of Crime Act 2002 (POCA).

This case indicates a shift in SFO enforcement practice toward a more victim-focused model, demonstrating that:

• the SFO will pursue asset recovery even where successful prosecution is no longer realistic;
• civil recovery will be used to return funds directly to victims, rather than to HM Treasury; and
• the passage of time does not prevent state-led recovery of property linked to unlawful conduct.

The decision has important implications for corporates, financial institutions, trustees and asset holders, particularly in relation to historic conduct, limitation periods and long-tail enforcement risk.

Background to the case

The recovery in the present case relates to an advance-fee email fraud scheme operated from the UK between 2001 and 2002 by Abdullah Ali Jammal, a former director of a retail-depositor bank.

Victims were falsely told that their assistance was required to release funds from jurisdictions including Nigeria, in return for commissions of between 10% and 25%. Eighteen individuals were defrauded, many suffering losses of tens of thousands of pounds, with total proceeds exceeding £4.4 million.

Mr Jammal fled the UK before he could be charged. By 2021, the SFO concluded that a criminal prosecution was no longer realistically achievable.

The SFO’s use of civil recovery powers

In the absence of a viable prosecution, the SFO pursued civil recovery proceedings to reclaim funds linked to the fraud. Accounts were frozen, including more than £150,000 destined for the family-controlled Jammal Trust Bank in Lebanon, an institution sanctioned by the United States for facilitating banking for a terrorist organisation.

The SFO took the additional and unusual step of:

• locating victims across multiple jurisdictions;
• securing their consent to the recovery approach; and
• coordinating with international partners including the FBI, Australian Federal Police, Belgian Police and the UK Foreign, Commonwealth and Development Office.

The recovered funds will be returned directly to nine victims, rather than paid into the Consolidated Fund.

The SFO has confirmed that it intends to deploy this approach in other appropriate cases.

Limitation periods under UK law: why this case matters

The age of this case highlights important distinctions between criminal proceedings, private civil claims and civil recovery under POCA.

Criminal proceedings

For serious fraud offences, there is no statutory limitation period under English law. Legally, prosecutions can be brought many years after the alleged conduct.

In practice, however, historic cases often face insurmountable obstacles, including evidential decay, witness availability and jurisdictional challenges. These factors may have led the SFO to conclude that a conviction was not realistically achievable.

Civil claims by victims

As the burden of proof is lower in civil cases, it may often be preferable for victims to bring a civil action for fraud. However, private civil claims are subject to the Limitation Act 1980:

• generally, claims must be brought within six years from the date the cause of action accrued; and
• in cases involving fraud or deliberate concealment, the six-year period runs from the date the fraud was discovered or could reasonably have been discovered (section 32).

Given that more than two decades have passed in the Jammal case, many victims would likely face significant limitation hurdles if attempting to recover losses through private litigation.

Civil recovery under POCA

Civil recovery proceedings under POCA operate on a fundamentally different basis:

• the focus is on recovering property obtained through unlawful conduct (proven to the civil standard, without the need for conviction);
• POCA does not impose a fixed limitation period equivalent to those under the Limitation Act;
• delay may be relevant to fairness, proportionality and the court’s discretion, but it is not an absolute bar to recovery.

This distinction enabled the SFO to pursue recovery decades after the fraud occurred, notwithstanding the absence of a conviction and the likely expiry of limitation periods for associated private civil claims.

Direct payment to victims

The SFO’s decision to return funds directly to victims represents a practical workaround to the limitations faced by victims, without disapplying the Limitation Act itself.

Why this is a significant development

This case signals:

• a more victim-centred approach to asset recovery;
• increased willingness by the SFO to use civil recovery creatively in long-running or stalled investigations; and
• expanded long-tail risk for individuals and entities connected to historic fraud or suspect assets.

Time alone can no longer be assumed to provide insulation from recovery action.

Practical implications for organisations

Organisations should consider:

• conducting historic exposure reviews, particularly where legacy matters were not prosecuted but there are clearly identifiable victims;
• asset-holding and trustee risk, including responsiveness to freezing orders and information requests;
• sanctions and high-risk jurisdiction exposure, especially where funds may be linked to unlawful conduct; and
• governance and record-keeping, given the potential for scrutiny many years after the relevant events.

Conclusion

The SFO’s recovery of funds nearly 24 years after the underlying fraud highlights that limitation periods do not definitively constrain the state’s ability to recover and redistribute property derived from unlawful conduct on behalf of victims. The case represents a meaningful evolution in enforcement practice and reinforces the need for organisations to manage historic risk.

How Gherson can help

At Gherson we provide expert criminal and civil law advice with regards to all aspects of fraud and financial crime, including civil recovery actions under the Proceeds of Crime Act 2002. We are committed to providing the highest levels of service in relation to complex cross border allegations in the most pressured circumstances.

If you are facing allegations of fraud or financial crime, regardless of the stage of the proceeding and need immediate expert advice on how to handle an investigation,  prosecution or other action, contact Gherson today. Our expert team is ready to provide strategic legal support, whatever your position.

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The information in this blog is for general information purposes only and does not purport to be comprehensive or to provide legal advice.  Whilst every effort is made to ensure the information and law is current as of the date of publication it should be stressed that, due to the passage of time, this does not necessarily reflect the present legal position.  Gherson accepts no responsibility for loss which may arise from accessing or reliance on information contained in this blog.  For formal advice on the current law please do not hesitate to contact Gherson.  Legal advice is only provided pursuant to a written agreement, identified as such, and signed by the client and by or on behalf of Gherson.

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